# Ontario Law Society Tribunal orders a lawyer to pay $31,150 in costs after Grok-generated fake citations

> In Mazaheri v Law Society of Ontario (2026 ONLSTH 112), the Law Society Tribunal ordered a suspended lawyer to pay the regulator's full costs of $31,150 after he filed motion materials produced by generative AI — which he admitted was 'in particular Grok' — that cited non-existent decisions and misused real ones. The panel called the AI misuse 'an additional and significantly aggravating factor' and noted it was the first time a party had put hallucinated authorities before the Tribunal.

- Verification status: pending
- Case type: deployment
- Provider: Generative AI (respondent's admission names Grok / xAI; the decision refers generically to 'generative artificial intelligence')
- Client: Law Society Tribunal (Hearing Division), Ontario — Mazaheri v Law Society of Ontario, 2026 ONLSTH 112, Legal profession regulation / courts (named)
- Sector: legal / CA / cross
- Canonical URL: https://theinternetninja.com/stories/mazaheri-v-law-society-ontario-onlsth-112-31150-costs-grok-ai-fabricated-citations-2026/
- Source: The Internet Ninja (theinternetninja.com), independent verified-proof platform

## Outcomes

| Metric | Before | After |
| --- | --- | --- |
| $31,150 (CAD) in costs ordered against the respondent, payable by June 26, 2026, with 4% interest on any overdue amount |  |  |
| Full costs awarded without any reduction; AI misuse held to be 'an additional and significantly aggravating factor' |  |  |
| First time a party has included 'hallucinated' authorities in arguments before the Law Society Tribunal |  |  |

## Verification method

Independent-origin tribunal decision (2026 ONLSTH 112), byte-tied to a Wayback capture; corroborated by two independent Canadian newsroom publishers (Newcom Media, Key Media).

## Full case file

## The problem
Shahryar Mazaheri, an Ontario lawyer whose licence had been suspended on an
interlocutory basis on November 12, 2024, brought motions before the Law Society
Tribunal to cancel or vary that suspension and to exclude the Law Society's
evidence. The factum, supplementary factum, affidavit and supplementary affidavit
he filed on November 14, 2025 were, in the panel's words, "produced using
generative artificial intelligence" and "the tool the applicant used was
hallucinating": they cited Tribunal decisions that do not exist, cited real cases
that did not support the propositions asserted, and pressed the Tribunal's Rules
of Practice and Procedure into service as substantive law.

## What was built
Nothing was deployed — this is an AI-governance record, not a vendor win. After
the panel flagged the materials in a November 25, 2025 case-management direction,
Mazaheri admitted on November 30, 2025 that his errors "arose for [sic] my
over-reliance on generative artificial intelligence tools (in particular Grok) to
assist me in researching and drafting the documents," and apologized. The panel
made no finding as to which product caused the fabrications; Grok is named only in
the respondent's own admission.

## The outcome
Both motions failed. On June 12, 2026 the three-member panel (Paul Aterman
(chair), Lubomir Poliacik, Michelle Richards) ordered Mazaheri to "pay costs to
the Law Society in the amount of $31,150 by June 26, 2026," with 4% interest on
any overdue amount. It awarded the Law Society's full costs without any reduction,
holding that his "irresponsible use of artificial intelligence not only wasted
time, cost, and effort, it was profoundly improper" and was "an additional and
significantly aggravating factor." The panel observed that, as far as it knew,
this was "the first time that a party has included 'hallucinated' authorities in
arguments before the Law Society Tribunal," and placed the case in a rising trend:
CanLII-indexed hallucination cases in Canadian courts and tribunals grew from
seven in 2024 to 86 in 2025 and 39 in the first quarter of 2026. Every figure
originates in the published tribunal decision — an independent adjudicator, not a
self-reporting party — and the decision expressly makes "no determination as to
whether the respondent has engaged in professional misconduct," which a separate
panel will decide.

## Path to green
The $31,150 and the AI findings are court-ordered facts from a published tribunal
decision, byte-tied to a Wayback capture and independently restated by two
Canadian newsroom publishers (Investment Executive / Newcom Media; Law Times and
Canadian HR Reporter / Key Media). No client-confirmation call is needed to
authenticate a published tribunal decision. The only human step remaining before a
green badge is Maneesh's editorial confirmation and a docket-currency check that no
reconsideration, appeal, or stay has vacated the $31,150 costs order.